I am submitting the…

I am submitting the following comments regarding the proposed Environmental Compliance Approval (ECA) for the Searchmont Ski Resort Wastewater Treatment Plant (WWTP) and its proposed discharge to the Goulais River.

 My comments are based on the information provided in the Design Brief (including the Assimilative Capacity Study), publicly available ERO postings, and provincial policies and guidelines. All references below are taken directly from the documents provided to the public

The Monitoring Dataset Does Not Meet MECP Expectations

The ACS is based on ~20 samples of data (January 2021–April 2022), with only 20 sampling events and 16–20 samples per parameter.

MECP typically expects:

3 years of seasonal data, or 2 years of monthly data

The ACS acknowledges that during consultation, the MECP raised concerns about the short duration, yet the dataset was still accepted.

This raises several questions:

The downstream location used for the water quality monitoring program done by the proponent was designated where the Goulais River crosses Hwy 17.    This is not the end of the river. It continues to flow well past this point and goes into Goulais Bay (with known water quality issues) Why was a shortened dataset accepted when it does not meet standard MECP expectations? What sampling protocol was used? Were samples collected consistently (same location, time of day, conditions)? How does taking multiple samples during summer compensate for missing winter and multi‑year data?

Conclusion:
The dataset is too limited to support a major surface‑water discharge approval. A strong data set is critical to prove that the river can receive and break down waste safely. With the spikes already showing up above the PWQO with no waste in the river – what will happen once effluent waste is introduced to the Goulais River? What will happen to Goulais Bay?